Last Revised: April 1, 2014
Notice of Privacy Rights of California Residents (see Section 10 below)
2. TYPES OF INFORMATION WE COLLECT
We may collect personally identifiable information from you, such as non-public information about you that helps SCP identify you, including, without limitation, first and last name, birth date, email address, home address, telephone number, and other information that is not otherwise publicly available. We also may collect non-personally identifiable information about you, such as information regarding your use of the Site, your IP address, Site usage statistics, time stamps, browsing history, general geographic location, type of device you use to connect to the Site, type of computer operating system you use (e.g., Microsoft Windows, Google Chrome OS or Mac OS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and whether you click on SCP’s digital ads. “Non-personally identifiable information” refers to information that does not personally identify the individual to whom the information relates, such as information that is aggregated by SCP or a third party, or information that is not linked to contact information or other personally identifiable information of an individual. In addition, we may collect information from you, such as your password, preferences and interests, income, education level, ethnicity, marital status, homeowner status, shopping habits, Site usage, age and gender. In the event that such information is maintained in a manner that identifies the name of, or contact information for, the individual to whom such information relates, it will be treated as personally identifiable information; otherwise, such information will treated as non-personally identifiable information,
3. HOW WE COLLECT INFORMATION
We may collect personally identifiable information and/or non-personally identifiable information from you when you use the Site or register to receive emails or newsletters, when you use the Wi-Fi Services, and when you participate in any events, promotions, sweepstakes, surveys, questionnaires, or other activities (collectively, “Activities”) that may be offered on the Site or offline. Information collected by SCP may be stored and processed in the United States in accordance with the laws of the United States, or in other jurisdictions. By using the Site or Wi-Fi Services, or by submitting your personally identifiable information to SCP online or offline, you expressly consent to the storage and processing of your personally identifiable information in the United States in accordance with the laws of the United States, or in other jurisdictions.
We may obtain personally identifiable and/or non-personally identifiable information from third parties such as the owners or operators of the websites or applications where our advertisements appear, and our affiliates, suppliers, vendors, merchants, licensors, or Activities partners or sponsors, and other sources (e.g., offline records or publicly available information). We may combine personally identifiable information we collect with information that we obtain from the owners or operators of the websites or applications where our advertisements appear, as well as from our affiliates, suppliers, vendors, merchants, licensors, or Activities partners or sponsors, and other sources (e.g., offline records or publicly available information). We will treat any such combined information as personally identifiable information.
SCP automatically receives and records non-personally identifiable information on our server logs from your browser as well as through other analysis of the Site. We also may collect information using cookies, web beacons, pixels, gifs, tags or other technologies (“Collection Technology”), or through third parties using similar technologies. Collection Technology may operate as a piece of data stored on your browser or device, or may identify, compile, aggregate and/or collect information through other means. When you visit the Site or use the Wi-Fi Services, your web browser may use Collection Technology to better enable you to navigate the Site during your visit and upon your return. You may use the Site even if you choose to reject or delete certain Collection Technology. Collection Technology also may be used by some of the other websites for which a link is placed on the Site. We may combine this non-personally identifiable information with personally identifiable information, and, if so, will treat the combined information as personally identifiable information.
4. HOW WE USE YOUR INFORMATION
We may use the information we collect:
• To provide information to third parties that may provide you with personalized content and advertising about their stores, restaurants, Activities, products and services.
• To alert you to new features, terms, Activities, stores, restaurants, products or services.
• To send emails or newsletters, and to provide you with personalized content in the newsletters.
• To monitor and analyze information regarding your browsing and viewing preferences.
• To analyze our users’ demographics and interests.
• To administer Activities.
• To process and respond to your inquiries.
• To improve the Site or the Wi-Fi Services.
• To support or operate the Wi-Fi Services, which may require us to share the information we collect with third-party service providers, contractors, or vendors that are retained by SCP for such purposes.
• For the purposes for which you provided the information.
In addition to the uses discussed above, SCP may use non-personally identifiable information in any manner so long as SCP uses such information in its de-identified form. These uses may include, without limitation, uses for Site administration; analysis of website trends and how the Site is used; improving navigation of the Site; analysis of the performance of the Site and diagnosis of problems; improving the services we offer; analysis and developing advertisements and advertising campaigns; and providing you with special offers and promotions and determine the effectiveness of same.
5. COMMUNICATIONS WITH YOU
You authorize SCP to transmit email to you to respond to your communications and administer Activities. If you participate in Activities, you agree that SCP is authorized to contact prospective winners by telephone, send information, documents and prizes to you by email or postal mail, and publish the names of prize winners; see applicable rules for more details. Unsubscribe instructions are included in each promotional email from SCP. Please note that such requests may take up to ten (10) days to become effective. You may not opt out of receiving communications regarding your dealings with SCP, the Wi-Fi Services, or the Site or technical information about the same.
6. INFORMATION SHARING WITH THIRD PARTIES
We also may use and share non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties in order to analyze usage of the Site or Wi-Fi Services; perform services on our Site or others’ sites or relating to the Wi-Fi Services; improve our services; improve our user experience; or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.
8. PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
SCP uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personally identifiable information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of SCP to intercept or access transmissions or private communications unlawfully. While we strive to protect personally identifiable information, neither SCP nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.
9. UPDATING YOUR INFORMATION
You are responsible for keeping your information current. You may update your information by contacting us at email@example.com We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to SCP’s internal reporting, processing and retention policies and all applicable legal obligations.
10. NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS
If you are a California resident and have provided personal information to SCP, you are entitled by law to request certain information regarding any disclosure that may have been made by SCP to third parties of personally identifiable information for their direct marketing purposes. To make such a request, send an email to firstname.lastname@example.org, specifying that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. SCP is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above email address.
We will not share your personally identifiable information with third parties for their direct marketing purposes if you request that we do not do so. You may make such a request by sending us an email at email@example.com
When contacting us, please indicate your name, address, email address, and what personally identifiable information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personally identifiable information or for processing this request.